throbber
Tingler, Robert Neal
`
`Case IPR2015-01292
`
`March 15, 2016
`
`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`----------------------------------------x
`WANGS ALLIANCE CORPORATION
`d/b/a WAC LIGHTING CO.,
` Petitioner,
` -against- Case IPR2015-01292
`KONINKLIJKE PHILIPS N.V., Patent 6,586,890
` Patent Owner.
`----------------------------------------x
`
` VIDEOTAPED DEPOSITION OF:
` ROBERT NEAL TINGLER
` Tuesday, March 15, 2016
` New York, New York
` 9:10 a.m. - 10:43 a.m.
`
` Reported in stenotype by:
` Rich Germosen, CCR, CRCR, CRR, RMR, CCRR
` NCRA, NJ and CA Certified Realtime Reporter
` NCRA Realtime Systems Administrator
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`Page 1 of 62
`
`PHILIPS EXHIBIT 2008
`WAC v. PHILIPS
`IPR2015-01292
`
`

`
`Tingler, Robert Neal
`
`Case IPR2015-01292
`
`March 15, 2016
`
`2
`
` Videotaped Deposition of ROBERT NEAL TINGLER,
`taken in the above-entitled matter before RICH GERMOSEN,
`Certified Court Reporter, (License No. 30XI00184700),
`Certified Realtime Court Reporter-NJ, (License No.
`30XR00016800), California Certified Realtime Reporter,
`NCRA Registered Merit Reporter, NCRA Certified Realtime
`Reporter, NCRA Realtime Systems Administrator, taken at
`the offices of RADULESCU, LLP, 350 Fifth Avenue, New
`York, New York 10118, on Tuesday, March 15, 2016,
`commencing at 9:10 a.m.
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`

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`Tingler, Robert Neal
`
`Case IPR2015-01292
`
`March 15, 2016
`
`3
`
`A P P E A R A N C E S:
`
`RADULESCU, LLP
`BY: MICHAEL SADOWITZ, ESQ.
` -and-
`BY: TIGRAN VARDANIAN, ESQ.
`The Empire State Building
`350 Fifth Avenue, Suite 6910
`New York, New York 10118
`(646) 502.5858
`michael@radulescullp.com
`tigran@radulescullp.com
`Attorneys for the Petitioner
`
`FINNEGAN HENDERSON FARABOW GARRETT & DUNNER, LLP
`BY: C. BRANDON RASH, ESQ.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`(202) 408.4000 / (202) 408.4400 (FAX)
`brandon.rash@finnegan.com
`Attorneys for the Patent Owner
`
`ALSO PRESENT:
`MARCELO RIVERA, Legal Video Specialist
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`Tingler, Robert Neal
`
`Case IPR2015-01292
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`March 15, 2016
`
`4
`
` I N D E X
`WITNESS EXAMINATION
`ROBERT NEAL TINGLER
` BY MR. RASH 7
`
` E X H I B I T S
`DESCRIPTION PAGE
`Exhibit 1006, previously 8
` marked entitled Declaration
` of Neal Tingler
`
`Exhibit 1003, previously 9
` marked United States Patent
` Biebl et al., Patent Number
` U.S. 6400101B1
`
`Exhibit 1005, previously 18
` marked entitled Current Mode
` PWM Controller
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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`5
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`PRODUCTION OF DOCUMENTS AND/OR INFORMATION
` Page Line
` (none)
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`DIRECTION TO WITNESS NOT TO ANSWER
` Page Line
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`QUESTIONS MARKED FOR LATER RULING
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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`--------------------------------------------------
` P R O C E E D I N G S
` 9:10 a.m.
` New York, New York
`--------------------------------------------------
` THE VIDEOGRAPHER: Stand by, please.
` This is DVD number one of the video
`deposition of Mr. Robert Tingler in the matter
`Koninklijke Philips NV, et al., versus Wangs
`Alliance Corp, et al. This deposition is being held
`at the law offices of Radulescu, located at 350
`Fifth Avenue, New York, New York, on March 15, 2016
`at approximately 9:10 a.m.
` My name is Marcelo Rivera. The court
`reporter is Rich Germosen in association with
`Henderson Legal Services, located at 1015 15th
`Street, Northwest, Suite 525, Washington, D.C.
` Will present counsel please introduce
`themselves for the record.
` MR. RASH: Brandon Rash from Finnegan
`Henderson Farabow Garrett & Dunner, LLP here on
`behalf of the patent owner, Koninklijke Philips NV.
` MR. SADOWITZ: Michael Sadowitz from
`Radulescu, LLP. With me is Tigran Vardanian here on
`behalf of Wangs Alliance Corporation and for the
`
`202-220-4158
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`Tingler, Robert Neal
`
`Case IPR2015-01292
`
`March 15, 2016
`
`7
`
`witness.
` THE VIDEOGRAPHER: Will the court
`reporter please swear in the witness.
` (Whereupon, the court reporter
`administered the oath to the witness.)
`
`R O B E R T N E A L T I N G L E R,
`residing at 469 North Waterway Drive, Satellite
`Beach, Florida 32937, having been first duly sworn
`or affirmed, was examined and testified as follows:
`EXAMINATION BY MR. RASH:
` Q. Good morning, Mr. Tingler.
` A. Hi.
` Q. Would you please state your full name
`for the record, please.
` A. Robert Neal Tingler.
` Q. Okay. Am I correct that we were here
`a few weeks ago for a deposition?
` A. We were.
` Q. Okay. Good. So I'll skip some of
`the formalities that we covered there, but same
`rules apply. If at any time today you need to take
`a break, just let me know and we'll take one.
` A. Okay.
` Q. And you do understand that you're
`
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`Tingler, Robert Neal
`
`Case IPR2015-01292
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`March 15, 2016
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`under oath today?
` A. I do.
` Q. Okay. And is there any reason that
`you cannot provide accurate and truthful testimony
`today?
` A. No.
` Q. Okay.
` MR. RASH: Actually, it's been
`marked. Let me see here.
` (Whereupon, previously marked
`entitled Declaration of Neal Tingler, is received
`and marked as Tingler Exhibit 1006 for
`Identification.)
`BY MR. RASH:
` Q. I've provided what's been previously
`marked as exhibit 1006. The title of the document
`is: Declaration of Neal Tingler.
` A. (Reviews.)
` Q. Is this the declaration that you
`provided in the IPR for U.S. Patent number 6586890?
` A. Yes.
` Q. And if I refer to your declaration,
`will you understand that this is the document that
`I'm referring to?
` A. Yes.
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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` Q. And I may also refer to the '890
`patent as well in the deposition. Will you
`understand that I'm referring to U.S. Patent number
`6586890?
` A. Yes.
` Q. Okay.
` (Whereupon, previously marked United
`States Patent Biebl et al., Patent Number U.S.
`6400101B1, is received and marked as Tingler Exhibit
`1003 for Identification.)
`BY MR. RASH:
` Q. And the second document you have has
`been previously marked as exhibit 1003.
` And this is U.S. Patent number
`6400101. Do you see that in front of you?
` A. I do.
` Q. And will you understand if I refer to
`U.S. Patent number 6400101 as Biebl?
` A. I will.
` Q. Okay. Thank you.
` Could you turn in your declaration to
`page 60 at paragraph 92.
` A. I'm here.
` Q. In the second sentence of paragraph
`92 do you see where you state that: Biebl discloses
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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`a control circuit that uses pulse width modulation
`control to drive an LED array?
` MR. SADOWITZ: Objection. Form.
` A. Uses pulse width modulation to drive
`the LED array. You said control.
` Q. Okay. I'm sorry. Yes, do you see
`where it says: Biebl discloses a control circuit
`that uses pulse width modulation to drive an LED
`array?
` A. I do.
` Q. Will you understand if I use the term
`PWM to refer to pulse width modulation?
` A. I will.
` Q. And then paragraph 92, are you
`referring to the circuit in figure eight of Biebl as
`using PWM?
` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. I will, yes.
` Q. So I see you've already turned to
`figure eight in Biebl itself. This is the figure
`that you're referring to in your declaration when
`you state that Biebl uses PWM?
` MR. SADOWITZ: Objection. Form.
` A. Yes.
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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` Q. And if I refer to the Biebl circuit,
`will you understand that I'm referring to the
`circuit in figure eight of Biebl?
` A. Yes.
` Q. Do you agree that the component in
`figure eight that's labeled comparator is involved
`in providing the PWM control?
` A. Yes.
` MR. SADOWITZ: Objection. Form.
` Q. And on the negative input of the
`comparator there is a sawtooth waveform labeled Ud.
` Do you see that?
` A. I see that.
` Q. And the box labeled sawtooth waveform
`generator, is that generating the Ud sawtooth
`waveform?
` A. Yes.
` Q. Have you heard of the term ramp
`signal in the context of PWM control?
` A. Yes.
` Q. And would the Ud sawtooth waveform on
`the negative input of the comparator be known in the
`art as a ramp signal for the PWM control in this
`circuit?
` A. Yes.
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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` Q. And would you agree that this
`sawtooth waveform Ud in the Biebl circuit has a
`constant ramp amplitude?
` A. Yes.
` MR. SADOWITZ: Objection. Form.
` A. It appears to from the look of it.
` Q. And would you also agree that the
`rising and falling slopes on the sawtooth waveform
`are constant?
` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. I would.
` (Reporter clarification.)
` A. Yes, I would.
` Q. And on the positive input of the
`comparator, do you see the label Ureg?
` A. I do.
` Q. And the Ureg signal is from the
`component labeled regulator?
` A. That's correct.
` Q. There is also a component labeled
`Rshunt.
` Do you see that?
` A. I do.
` Q. And is resistor Rshunt sensing
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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`current to the LEDs?
` MR. SADOWITZ: Objection. Form.
` A. It is sensing current that's flowing
`through the LEDs to ground, yes.
` Q. Is the -- is it your understanding
`that the Biebl circuit in figure eight is providing
`a pulsed current to the LEDs?
` MR. SADOWITZ: Objection. Form.
` A. Yes.
` Q. And is the pulse current that the
`Biebl circuit is providing to the LEDs, does that
`current have a constant mean value?
` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. Well, it has a constant mean value
`based on the duty cycle of the actual pulse itself.
` Q. Right. And you would agree though
`that the Biebl circuit is configured to provide
`current to the LEDs with a constant mean value?
` MR. SADOWITZ: Objection. Form.
` A. Yes, that's its intention.
` Q. And so would a person of ordinary
`skill understand that the Biebl circuit is using
`current regulation to maintain the constant mean
`current to the LED?
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. Yes, they're regulating on the
`current.
` Q. Do you see the component labeled
`integrator that is between the regulator and the
`resistor Rshunt?
` A. I do.
` Q. Is the component labeled integrator
`what is providing the mean value of the LED current
`to the regulator?
` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. It's averaging into a DC level the
`pulse current going through Rshunt.
` Q. So my question was: Is the component
`labeled integrator providing the mean value of the
`LED current to the regulator?
` MR. SADOWITZ: Same objections.
` A. Yes.
` Q. And then is the regulator then
`providing a constant DC signal feedback labeled Ureg
`to the comparator that is based on the sensed LED
`current?
` MR. SADOWITZ: Objection. Form.
`
`202-220-4158
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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`Foundation.
` A. Well, it's providing a DC level
`that's based on the actual DC signal going into the
`positive of the regulator. So if the input voltage
`varies, then that level will vary going into the
`positive of the regulator, so the output of the
`regulator can vary based on the DC level of the
`battery. So it's not constant. It can vary and
`that's how it maintains its current.
` Q. Would you agree that the Biebl
`circuits configured to try to keep Ureg -- the Ureg
`signal as close as possible to the reference
`voltage?
` MR. SADOWITZ: Objection. Form.
` A. I would agree.
` Q. And is the reference voltage
`constant?
` A. It is.
` Q. If we could go back to --
` A. One exception. The reference voltage
`has in -- it's configured to be a constant, but it
`does have inputs for summing for temperature
`regulation issues. You can see it attached to the
`NTC pin through the temp regulation so the reference
`voltage can vary based on external inputs.
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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` Q. Would it vary based on any other
`external input besides temperature?
` A. Not as shown. I'm sorry, based on
`the R external as well.
` Q. And is that a resistor?
` A. Yes.
` Q. And so would that be fixed?
` A. It would be fixed, but yes.
` Q. So once you set that, it would be
`constant?
` A. Correct.
` Q. Now, if you could turn back to
`paragraph 92 of your declaration. Let's see. Do
`you see in the second to last sentence of paragraph
`92 you refer to Biebl as disclosing sensing the
`current and comparing that sensed current to an
`internal referenced signal?
` A. I do.
` Q. And when you're referring to sensing
`current in Biebl in paragraph 92, are you referring
`to sensing the current to the LEDs with the constant
`mean value?
` MR. SADOWITZ: Objection. Form.
` A. I'm referring to -- referring the
`sensing the current through the Rshunt value. So
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`March 15, 2016
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`that's the means for sensing the current through the
`LEDs.
` Q. And we just had discussed previously
`correctly that the integrator takes that pulsed
`current and provides a constant mean value to the
`regulator; is that right?
` MR. SADOWITZ: Objection. Form.
` A. A constant mean value based on that
`signal, yes, based on the integrated signal, but
`that signal can vary some if the duty cycle is
`adjusted, but yes.
` Q. Have you heard of the term direct
`duty cycle control in the context of PWM control?
` A. Yes.
` Q. Does direct duty cycle control refer
`to a PWM control method where a waveform generator,
`like the one in the Biebl circuit, generates a ramp
`signal with a constant ramp amplitude?
` MR. SADOWITZ: Objection. Form.
` A. Could you repeat the question,
`please?
` Q. Sure.
` Does direct duty cycle control refer
`to a PWM control method where there is a waveform
`generator generating a ramp signal with a constant
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`ramp amplitude?
` MR. SADOWITZ: Same objection.
` A. I would say, yes.
` Q. So you would agree that Biebl circuit
`is using a direct duty cycle control for PWM
`control?
` MR. SADOWITZ: Objection. Form.
` A. Yes.
` (Whereupon, previously marked
`entitled Current Mode PWM Controller, is received
`and marked as Tingler Exhibit 1005 for
`Identification.)
`BY MR. RASH:
` Q. I've handed you what's been
`previously marked as exhibit 1005.
` A. (Reviews.)
` Q. And the title of the document is:
`UC2842/3/4/5 UC3842/3/4/5 Current Mode PWM
`Controller.
` Is that what you have?
` A. It is.
` Q. And is this the ST Micro Datasheet
`that you referred to in your declaration?
` A. It is.
` Q. And will you understand if I refer to
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`exhibit 1005 as the ST Micro Datasheet, you'll
`understand that I'm referring to this exhibit?
` A. I will.
` Q. And could we go back to paragraph 92
`in your declaration.
` A. I'm there.
` Q. In paragraph 92 do you see in the
`middle where it states that: The ST Micro Datasheet
`discloses a commercially available control circuit,
`the UC2842 family of current mode pulse width
`modulation control ICs, to drive a load?
` A. I do.
` Q. So are you stating that ST -- the
`ST Micro Datasheet discloses PWM control?
` MR. SADOWITZ: Objection. Form.
` A. Yes, it is a PWM controller.
` Q. And could you turn back one page to
`page 59 in paragraph 90 of your declaration. Are
`you referring to the block diagram on page one of
`the ST Micro Datasheet as using PWM control?
` MR. SADOWITZ: Objection. Form.
` A. I'm sorry, could you repeat that?
` Q. Sure.
` Are you referring to the figure on
`page one of the ST data micro sheet -- Micro
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`Datasheet, which is on page 59 of your declaration,
`are you referring to that block diagram and the
`circuit in that block diagram as using PWM control?
` MR. SADOWITZ: Objection. Form.
` A. I guess so. I'm just a little bit
`confused why you had me turn to page 58 and then you
`were referencing page 59.
` Q. Oh, I'm sorry. If I said 58, I
`apologize. I meant to say page 59, paragraph 90.
`Are you in paragraph 90 now?
` A. I'm there.
` Q. Okay. Sorry for that. I'll restate
`the question.
` So you had just testified I believe
`that the ST Micro Datasheet uses PWM control;
`correct?
` A. Correct.
` Q. And so in paragraph 90, is this
`showing a block diagram from page one of the ST data
`micro sheet?
` A. It is.
` Q. I'm sorry. I said that backwards.
`From the ST Micro Datasheet?
` MR. SADOWITZ: Objection. Form.
` A. It is, yes.
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` Q. Okay. And are you referring to the
`block diagram on page one of the ST Micro Datasheet
`as using PWM control?
` MR. SADOWITZ: Objection. Form.
` A. I am.
` Q. If we could turn back to the ST data
`micro sheet -- ST Micro Datasheet. I'm going to say
`that backwards all day.
` A. I'm with you.
` Q. When did you first see the ST Micro
`Datasheet?
` A. During review for the IPR or
`generation of the IPR.
` Q. You had not seen the ST Micro
`Datasheet prior to the IPR?
` A. There is a chance that I have in
`looking up parts, but I can't specifically say that
`I had.
` Q. So you could not identify a specific
`time that you had seen the ST Micro Datasheet prior
`to this IPR?
` MR. SADOWITZ: Objection. Form.
` A. Correct, yes.
` MR. SADOWITZ: Please let me get my
`objections in.
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` THE WITNESS: Oh, sorry.
`BY MR. RASH:
` Q. Now, am I correct that in your
`declaration you state that you have experienced
`working with data sheets from STMicroelectronics?
` A. Yes.
` Q. Do you recall your first experience
`with an STMicroelectronics Datasheet?
` MR. SADOWITZ: Objection. Relevance.
` A. Probably 2003ish, 2002. Somewhere in
`there. I don't know the exact date, but somewhere
`around there.
` Q. Do you recall anything else about the
`first experience with an ST Micro Datasheet?
` MR. SADOWITZ: Objection. Relevance.
`Scope.
` A. I don't.
` Q. Do you recall your latest experience
`with an STMicroelectronics Datasheet prior to this
`IPR?
` MR. SADOWITZ: Objection. Relevance.
`Scope.
` A. Probably 2015. No, I'm sorry,
`actually 2016.
` Q. And you do not recall any experience
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`with ST Micro Datasheets prior to the 2003ish or
`2002 time frame?
` A. I apologize for the ish.
` MR. SADOWITZ: Same objections.
` Q. I just wanted to be accurate.
` A. No, sir, I do not.
` Q. Okay. So could you turn to page one
`of the ST Micro Datasheet.
` A. I'm there.
` Q. Is the component in the block diagram
`labeled current sensed comparator the PWM comparator
`in the circuit?
` A. It is.
` MR. SADOWITZ: Objection. Form.
` Q. Is the negative input of the current
`sensed comparator the input with a circle on it?
` A. Yes.
` Q. Okay. And is it correct to say that
`there is a reference signal on the negative input?
` A. I would say --
` MR. SADOWITZ: Objection to form.
` A. -- it is correct. It's -- the signal
`coming in is the control voltage from the error
`amplifier which itself has a referenced signal
`coming into it which is compared to the feedback
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`voltage Vfb, and that is the amplified error voltage
`between the two. So it is a portion of the
`referenced voltage. So the referenced voltage is
`coupled to it and then fed into the negative of the
`current sensed comparator.
` Q. And am I correct that you refer to
`the signal on the negative input of the current
`sensed comparator as the referenced signal in your
`declaration?
` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. Could you point me to the section in
`the declaration?
` Q. Sure. Sure. Sure.
` So on page 66 of your declaration in
`paragraph 101 do you see at the start of that
`paragraph you refer to the referenced signal?
` A. I do.
` Q. And by the referenced signal are you
`referring to -- and you say further in that sentence
`that: The referenced signal is by definition
`compared to the sensed current signal; is that
`right?
` A. Could you say that again, please?
` Q. You further say in the same sentence
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`there in paragraph 101 that: The referenced signal
`is by definition compared to the sensed current
`signal?
` A. Yes.
` Q. And when you use the term referenced
`signal there, are you referring to the signal on the
`negative input of the current sensed comparator?
` A. Yes, that becomes the referenced
`signal when using the current sensed comparator
`right there. So in the alternative implementation
`with Vfb, so yes, correct.
` Q. So if we could turn back to the page
`one of the ST Micro Datasheet, is it correct to
`refer to the input without the circle on it as the
`positive input of the current sensed comparator?
` A. Correct.
` Q. And the positive input of the current
`sensed comparator is connected to current sense pin
`three?
` MR. SADOWITZ: Objection. Form.
` A. Yes.
` Q. Could you turn to page eight of the
`ST Micro Datasheet.
` A. I'm there.
` Q. Do you see figure 11 labeled offline
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`flyback regulator?
` A. I do.
` Q. And do you rely on figure 11 in your
`declaration to show a flyback converter?
` MR. SADOWITZ: Objection. Form.
`Foundation.
` A. I believe we reference a flyback
`converter from figure 11 in the declaration.
` Q. Could you turn in your declaration to
`page 90. That's where paragraph 135 begins and
`actually goes on to paragraph -- oh, I'm sorry, on
`to page 91. Looking at that paragraph would you
`agree that your declaration is relying on figure 11
`to show a flyback converter?
` MR. SADOWITZ: Objection to form.
` A. Yeah, the declaration shows -- refers
`to figure 11 which is a flyback converter.
` Q. Right. I guess my question is: Are
`you relying on figure 11 in your declaration to show
`a flyback converter?
` MR. SADOWITZ: Objection. Form.
` A. I guess maybe I don't understand the
`term relying on. We refer to a flyback converter in
`reference one from the ST Micro Datasheet in figure
`11.
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` Q. Right. So I'm not asking whether or
`not you're referring to a flyback converter in the
`ST Micro. I'm asking if your declaration is relying
`on -- maybe the better thing -- let me strike that.
` So in the first sentence you state --
`of paragraph 135: The ST Micro Datasheet discloses
`an application circuit for an offline flyback
`regulator, which is a flyback converter; correct?
` A. Correct.
` Q. And so from that is it fair to say in
`your declaration you're relying on the ST Micro
`Datasheet to disclose the claimed flyback converter?
` MR. SADOWITZ: Objection. Form.
` A. I guess it's the term relying on that
`may be from a legal standpoint I don't understand.
` Q. Okay.
` A. What I'm trying to say is the
`ST Micro Datasheet which is used in buck,
`buck-boost, flyback converters, commonly discloses a
`use of an offline flyback. So it shows a use of a
`flyback for the 3842 in an application.
` Q. Okay. So if we could turn back to
`figure 11 on page nine of the ST Micro Datasheet.
` A. Yes.
` Q. Does figure 11 show current sensed
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`pin three as the bottom right pin?
` A. It's poorly printed, but I would say
`that is -- I would agree that is a current sensed
`pin.
` Q. And is current sensed pin three
`connected to transistor Q1 through a resistor?
` A. Yes.
` Q. Do you see a transformer in figure
`11?
` A. I do.
` Q. Can you describe where the
`transformer is in figure 11?
` MR. SADOWITZ: Objection to form.
` A. The transformer, the primary side is
`one end tied to the input positive voltage. The
`other end of that winding is tied to the drain of
`MOSFET Q1 and secondary output is tied to load -- I
`believe it's 5-volt load -- 5-volt load or a 5-volt
`output that's capable of providing four amps per the
`data sheet or per the drawing.
` Q. So you stated that the transformer
`has a primary side and a secondary side; is that
`correct?
` A. Yes, this is an isolated application.
` Q. So I guess in layman's terms would it
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`be correct to say that the circuitry on the left
`side of the transformer is on the primary side?
` MR. SADOWITZ: Objection to form.
` A. That is correct.
` THE WITNESS: Sorry.
` Q. And then the circuitry on the right
`side of the transformer is on the secondary side?
` MR. SADOWITZ: Objection. Form.
` A. Correct.
` Q. Would you agree that current from the
`inductor on the primary side of the transformer is
`going through transistor Q1?
` A. I would agree.
` Q. And is current sensed pin three
`sensing the inductor current that's going through
`the transistor Q1?
` MR. SADOWITZ: Objection. Form.
` A. Yes, it is.
` Q. And I believe earlier we established
`that current sensed pin three is connected directly
`to the PWM comparator inside of the

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